Factor Fiction: Navigating Denominator Dilemmas

With many states shifting to a single sales factor to apportion taxable income, determining what is included in the sales factor has become a critical battleground for taxpayers. Among other things, changes by the TCJA (and OBBBA) have caused states to focus on the composition of the sales factor denominator. Recent court decisions and administrative guidance are constantly reshaping which receipts must be included in the “everywhere” denominator, significantly impacting a company’s overall state tax apportionment. This panel will discuss the latest developments, trends and controversies surrounding the sales factor denominator.

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